The Tax Institute, Chartered Accountants Australia and New Zealand, Corporate Tax Association, the Group of 100 and the Business Law Section of the Law Council of Australia (Joint Bodies) welcome the opportunity to make a submission to the Australian Taxation Office (ATO) in relation to the Practical Compliance Guideline PCG 2018/D3 “ Income Tax: central management and control test of residency: identifying where a company's central management and control is located (Draft PCG).
Our submission addresses our main concerns in relation to the Draft PCG. In particular, the interpretation being given to the corporate residency test; Technical issues with the Draft PCG; and Requirement for a further review of the corporate residency test.